BILL ANALYSIS                                                                                                                                                                                                    �




                     SENATE GOVERNANCE & FINANCE COMMITTEE
                            Senator Lois Wolk, Chair
          

          BILL NO:  SB 1378                     HEARING:  5/7/14
          AUTHOR:  Morrell                      FISCAL:  Yes
          VERSION:  4/7/14                      TAX LEVY:  Yes
          CONSULTANT:  Urquiza                  

                INCOME TAXES: CREDITS: CHARITABLE CONTRIBUTIONS
          

               Enacts a tax credit for contributions to qualified  
                           charitable organizations.


                           Background and Existing Law  

          Federal and state laws allow taxpayers to claim an income  
          tax deduction for charitable contributions.  The deduction  
          lowers the amount of income on which the tax rate is  
          levied, reducing the taxpayer's tax liability.   For  
          example, a taxpayer with $100,000 of annual income is  
          subject to a state rate of 9.3% and a federal rate of 35%.   
          Therefore, if the taxpayer makes a $100 contribution to a  
          charity, a $100 reduction in the taxpayer's taxable income  
          generates a $10 benefit from the state, and about a $35  
          benefit from the federal government.  These benefits create  
          a charitable giving incentive for taxpayers.  Deductions  
          for cash donations may not exceed 50 percent of a  
          taxpayer's adjusted gross income.  A contribution made in  
          excess of the percentage limitations may be carried over  
          and deducted in future years. 

          Unlike deductions, which reduce the amount of earnings that  
          are taxed, tax credits are applied after the taxable income  
          is calculated and reduces-dollar for dollar-the amount of  
          taxes owed, usually up to the ceiling on the tax credit or  
          a percentage of the taxpayer's costs or contributions.   
          California provides various tax credits designed to provide  
          incentives for taxpayers that incur certain expenses, such  
          as child adoption, or to influence taxpayers' behavior,  
          such as research credits.  The Legislature typically enacts  
          tax credit to encourage taxpayers to do something that, but  
          for the tax credit, they would not otherwise do.

          A handful of states, including Arizona, Michigan, North  
          Carolina, and Missouri have enacted state charity tax  




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          credits to stimulate charitable giving.  Unlike the  
          charitable tax deduction that is available for  
          contributions to any 501 (c) (3) or religious organization,  
          charitable tax credits typically are restricted to  
          contributions to specific types of charities, such as those  
          directly serving the poor. 




                                   Proposed Law

           Senate Bill 1378 enacts a tax credit against the Personal  
          Income Tax for charitable contributions to qualified  
          charitable organizations, for each taxable year beginning  
          on or after January 1, 2014.  The credit is equal to the  
          amount donated by the taxpayer during the taxable year and  
          cannot exceed:
                 $250 for individuals filing as either single or as  
               a head of household, or married taxpayers filing  
               separate returns; or
                 $500 for married taxpayers filing joint returns or  
               an individual filing as a surviving spouse.

          SB 1378 defines a "qualified charitable organization" as an  
          organization that meets all of the following requirements: 
                 Is an organization that is exempt under Internal  
               Revenue Code section 501(c)(3) or is a designated  
               community action agency that receives community  
               services block grant moneys;
                 Spends at least 50% of its budget on services to  
               California individuals who receive California Work  
               Opportunity and Responsibility to Kids (CalWORKS)  
               benefits, are low-income individuals whose household  
               income is less than 150% of the poverty guidelines,  
               are chronically ill, or are physically disabled  
               children;
                 Demonstrates that it plans to continue to spend at  
               least 50% of its budget on services to those persons  
               listed above;
                 Applies for certification from the Franchise Tax  
               Board (FTB) and receives such certification that the  
               organization meets all of the requirements. 

          SB 1378 requires FTB to post the names of the qualified  
          charitable organizations on its Internet web site. 





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          The bill allows for credits in excess of the net tax to be  
          carried over to reduce the net tax in the following year  
          and succeeding four years, until exhausted. The tax credit  
          is in lieu of any charitable deduction otherwise allowed. 


                               State Revenue Impact
           
          According to the Franchise Tax Board, a credit with a  
          $250/$500 cap for each taxpayer would result in an  
          estimated revenue loss of $300 million in 2014-15, $45  
          million in 2015-2016, and $18 million in 2016-17.  Should  
          the measure be amended per comment #8, revenue loses would  
          be significantly higher. 





                                     Comments  

          1.   Purpose of the bill  .  According to the author, "This  
          bill will offer charities an ability to market to their  
          donors. The opportunity to genuinely give back to the  
          community through supporting charitable organizations is an  
          uplifting experience that more people should have.  With  
          this bill, California rewards and incentivizes the chance  
          to help make a difference in the life of another  
          individual. Providing tax credit for charitable giving is  
          an excellent way to make sure that charities can continue  
          with their work, especially given the current economic  
          climate.  The United States has seen an unfortunate  
          decrease in donations in the past eight years.  In  
          California alone, the average charitable contribution per  
          return dropped by over 200 dollars between 2006 and 2011.  
          Giving tax payers the opportunity to claim a tax credit for  
          cash contributions will benefit charities and the  
          communities alike."

          2.   Redirection or new money  ?  The underlying motives for  
          charitable giving are complex and not fully understood by  
          economists.  Empirical studies generally find that, to some  
          degree, taxpayers respond to the after-tax price of giving  
          to some degree.  According to a report from the Johnson  
          Center for Philanthropy, Michigan residents significantly  





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          decreased donations between 2011 and 2012 due to the  
          expiration of the Michigan Community Foundation Tax Credit.  
           In Arizona, creating a tax credit for donations to  
          charities seems to have resulted in additional donations to  
          the nonprofit sector.  However, a 2004 study by the Urban  
          Institute Center on Nonprofits and Philanthropy on  
          Arizona's tax credit found that it was not clear if  
          taxpayers generated a "substitution effect" away from some  
          charities by redirecting their contribution to the  
          certified charitable organizations.  Although a tax credit  
          may entice new taxpayers to contribute to charities, a tax  
          credit may also redirect contributions from charities that  
          currently receive them to charities that qualify under the  
          tax credit program. 

          3.   Oversight  .  Charitable tax credits reduce taxpayer's  
          state income tax liability dollar-for-dollar, which means  
          that those gifts are free.  While SB 1378 gives certain  
          nonprofits the opportunity to market a no-cost donation to  
          taxpayers, it might also create an industry of illegitimate  
          nonprofits pooling donations for purposes other than  
          serving underserved communities.  It is unclear whether FTB  
          has the authority to reliably certify and audit qualified  
          charitable organizations to ensure that they are spending  
          their resources as intended under the tax credit  
          guidelines.  The committee may wish to consider the  
          unintended consequences of enacting a tax credit for  
          donations to charitable organizations without a mechanism  
          to ensure that the qualified charitable organizations are  
          complying with state law. 

          4.   Tradeoffs  .  While providing tax credits can promote  
          charitable giving, SB 1378 will result in revenue losses,  
          which have to be paid for with higher taxes on others or  
          reduction in services.  The Committee may wish to consider  
          whether SB 1378 is a cost-effective way to grow charitable  
          giving and whether it is worth the tradeoff of cuts in  
          spending or raising taxes to offset foregone revenue.


          5.  Let's be clear  .  The bill states that its credit is in  
          lieu of a charitable deduction. This has the effect of  
          denying all charitable deductions, not just the deduction  
          for this contribution, including a deduction amount that is  
          above the cap on the tax credit.  This can have the  
          unintended consequence of discouraging charitable donations  





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          in excess of the cap if a taxpayer is not able to deduct  
          the rest of his or her donation.  The committee may wish to  
          consider amending the bill to limit the denial of a  
          deduction to amounts that provide the basis for the credit.  
           The bill also uses phrases that are undefined, such as  
          "chronically ill," "physically disabled children," and  
          "services."  The absence of definitions to clarify these  
          phrases could complicate the administration of the credit.   
          The committee may wish to consider amending the bill to  
          define these terms.

          6.   Delayed implementation  .  FTB must certify a qualified  
          charitable organization before implementation of the tax  
          credit.  The committee may wish to consider amending the  
          bill to delay implementation to January 1, 2016, to give  
          FTB time to develop policies and guidelines to certify  
          qualified charitable organizations. 

          7.   Lack of sunset and reporting  .  As drafted, this bill  
          has no sunset date.  Sunset dates enable the Legislature to  
          review the efficacy of tax expenditure programs in the  
          future.  In addition, this bill lacks any provision  
          requiring FTB to report back to the Legislature regarding  
          credit utilization. 
           
          Committee staff recommends the following amendments:
                 Adding a sunset date of December 1, 2019.
                 Requiring FTB, or another entity, to report back to  
               the Legislature on credit utilization and  
               effectiveness. 

          8.   Ongoing or one-time  ?  SB 1378 creates a nonrefundable  
          credit for individuals who make contributions to a  
          qualified charitable organization for each taxable year  
          beginning on or after January 1, 2014.  However, the  
          measure caps the total tax credit amount at $250/$500, so  
          if the taxpayer donates above that amount, they can't claim  
          the credit in the future.  The Committee may wish to  
          consider applying the cap to each taxable year instead of  
          on each taxpayer.


                         Support and Opposition  (5/1/14)

           Support  :  Unknown. 






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           Opposition  :  Unknown.